The enforcement of the Corporate Transparency Act (CTA) and related regulations, including the requirement that entities formed or registered in the United States file a Beneficial Ownership Information Report (BOIR), is back in effect. The new deadline to file an initial, updated, and/or corrected BOIR is March 21, 2025. However, reporting companies that were previously given a reporting deadline later than March 21, 2025 have until that later deadline to file their initial BOIR.
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a statement which extended the deadline following a February 18, 2025 decision by the U.S. District Court for the Eastern District of Texas to lift the nationwide preliminary injunction issued in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (E.D. Tex.). FinCEN also indicated that it will assess its options to further modify deadlines to reduce regulatory burden on businesses and indicated that it may provide an update before March 21st if there are any further modifications of this deadline. You may check the FinCEN website for any updates at https://www.fincen.gov/boi.
The CTA imposes reporting obligations that require most entities (LLCs, corporations, etc.) formed or doing business in the United States to report their beneficial ownership information to the FinCEN. Please see our prior CTA-related client alerts here and here for additional information about the filing requirements and the applicable exceptions, and do not hesitate to reach out to your contacts at Sullivan if you have any questions about CTA compliance or BOIR filing requirements.
